Permanent Establishment

Ever hear the saying “You get what you pay for”? That is precisely what most do-it-yourselfers (DIY, for short) get when they formulate their own international tax plans. Recently I was reintroduced to an international structure, that over the years, I have seen international tax wannabes dream up in one variation or another.

This elegant and flawless structure (I hope my sarcasm is coming across), generally, has a backstory that goes something like this. A U.S. taxpayer, living in the U.S., has a product that he sells or wants to sell to third-party buyers in the U.S. and elsewhere, but usually it’s mostly in the U.S. The product is generally manufactured by a third-party in China, Vietnam, or some other low-cost manufacturing jurisdiction.